The UAE Federal Tax Authority has released a list of Frequently Asked Questions (FAQs) on its Domestic Minimum Top-up Tax (DMTT) webpage to clarify the new legislation. Here are the key questions addressed:
- Has the OECD reviewed the legislation and given it qualified status?
- Why did the UAE choose not to implement the Income Inclusion Rule (IIR)?
- The UAE’s DMTT rules allow some deviations from the GloBE rules. Why were certain variations made, such as why the Cabinet decision does not exclude non-wholly owned entities?
- Why do some articles in the legislation refer to themselves, like Article 9.1.5 in Cabinet Decision 142 of 2024?
- Is Financial Accounting Net Income and Loss based on local accounting standards or Consolidated Financial Statements? If based on local standards, will this cause Safe Harbour issues?
- Will the UAE adopt the OECD’s Administrative Guidance and Commentary as is, or are changes expected?
- If I am exempt from UAE Corporate Tax or qualify for the 0% rate as a Qualified Free Zone Person, do I need to comply with Cabinet Decision No. 142 of 2024 regarding the Top-up Tax on Multinational Enterprises?
- Why is the Cabinet Decision dated 2024 when it was published in 2025?
- Why does the English version in the Official Gazette not reference an actual law? Is this a mistake?
- I am exempt from UAE Corporate Tax or eligible for the 0% rate as a Qualified Free Zone Person. Do I need to comply with Cabinet Decision No. 142 of 2024?
- There is conflicting advice in the market. Where can I get clarification from a trusted source?
- When can we expect further guidance?
Earlier, the UAE Ministry of Finance published a copy of Cabinet Decision No. 142 of 2024, detailing the country’s Domestic Minimum Top-up Tax (UAE DMTT) law.
